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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
March 5, 2020
NAAA Submits Comments on UAS Tracking and ID Requirements

This week NAAA submitted comments to the FAA on the agency’s long-awaited proposed rule on the tracking and identification of UAS. With nearly 1.5 million UAS and 155,000 remote pilots registered with the FAA, UAS tracking and ID is widely viewed as the lynchpin for enforcing all other UAS related rules. The proposed rule received over 52,000 comments from various stakeholders.  


NAAA’s comments were largely in support of the proposed rule, with a heavy emphasis on supporting the requirement that all UAS weighing over 0.55 lbs. must be subject to tracking and ID requirements.  NAAA explained it is extremely difficult for manned aircraft to see UAS, and particularly difficult for agricultural aviators conducting operations 10 feet off the ground at speeds up to 140 mph with high cockpit workloads. Additionally, NAAA explained birds weighing as little as 1 to 2 pounds can severely damage aircraft. Studies have shown UAVs of similar size cause much more damage because they are made of denser materials such as plastic and batteries, while birds are made of feathers, hollow bones, sinew and soft tissue.


A weight-based threshold is welcome news, as NAAA was one of 10 members of the 2017 Unmanned Aircraft Systems Identification and Tracking Aviation Rulemaking Committee (UAS ID and Tracking ARC) to dissent from the ARC’s final report. In a dissenting letter, NAAA explained why lacking a weight-based threshold for compliance with the rules could “greatly undermine the value, benefits and utility of UAS ID and Tracking – not to mention, jeopardize the safety of the airspace and comprehensiveness of any future [unmanned traffic management system].”


A UAS not equipped with remote ID would only be allowed to fly in "FAA-recognized" areas and would have to stay within visual line of sight. NAAA commented it is essential these designated areas are located where there is absolutely no low altitude manned aircraft activity. This includes public and private airports, helipads (including hospitals with helipads) as well as around rural agricultural plots of land where manned ag aircraft typically operate. NAAA wrote appropriate areas include parks near residential neighborhoods or other areas where a manned aircraft would never be authorized.


The proposal would not allow any non-compliant UAS to be manufactured in the U.S. within two years of the effective date of the rule, and within three years all UAS operating in the national airspace would have to meet the rule requirements. NAAA commented that it implementing the rule should occur sooner than the three years FAA plans to begin implementing the tracking and ID rules due to the extreme likelihood of additional accidents between UAS and manned aircraft as the number of UAS flown will markedly increase.


You can read a summery of the proposed tracking and ID requirements here.


Click Image to Enlarge

Image Source: FAA


You can read NAAA’s comments here and also browse the over 52,000 other public comments submitted to the FAA here.

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This newsletter is intended for NAAA members only. NAAA requests that should any party desire to publish, distribute or quote any part of this newsletter that they first seek the permission of the Association. The views, thoughts, and opinions expressed herein do not necessarily represent those of the National Agricultural Aviation Association (NAAA), its Board of Directors, staff or membership. Items in this newsletter are not the result of paid advertising and are only meant to highlight newsworthy developments. No endorsement by NAAA is intended or implied.
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